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Recent Posts

  • Calling All Bank Directors September 29, 2021
  • Updated Summary of Key Provisions HR 748 April 4, 2020
  • 199A Final Regulations: Loan Sales are included but Trust Income is not April 1, 2019
  • Section 199A Final Regulations for Subchapter S Banks- Webinar 2/21/2019 February 25, 2019
  • Joint letter of ABA, ICBA and Sub S Bank Associations October 10, 2018

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Archives for February 2014

February 28, 2014

Enhancing Transparency in the Federal Reserve’s Applications Process

On February 24, the Federal Reserve Board announced in SR 14-2 that it will start publishing a semi-annual report to provide certain information on bank applications and notices filed with the Federal Reserve. The guidance applies to all financial institutions supervised by the Federal Reserve, including those with $10 billion or less in consolidated assets. The purpose of SR 14-2 is to provide a better understanding of the Federal Reserve’s approach to applications and notices that may not satisfy statutory requirements for approval of the proposal or otherwise raise supervisory or regulatory concerns.

Federal Reserve Board, SR 14-2

February 7, 2014

CFPB Considers Expanding HMDA Reporting Requirements

CFPB is questioning whether to increase the data collected under the Home Mortgage Disclosure Act to better monitor trends and abuses in the market. This would possibly requiring lenders to explain why they rejected a loan and whether they thought it was a so-called “qualifying mortgage.” In addition, financial institutions would have disclose an applicant’s debt-to-income ration, the interest rate, the total origination charges, and the total discount points of the loan.

Dodd-Frank, mortgage loans, qualified mortgage

February 7, 2014

ABA & Subchapter S Bank Association Seeks Action

ABA urged federal regulators to remedy a provision in the Basel III capital standards that disadvantages the 2,000 community banks organized as Subchapter S corporations.

Basel III

February 4, 2014

‘Heightened Expectations’ for Banks

The OCC recently released proposed amendments to its Part 30 regulations, which reflect the agency’s “heightened expectations” for large banks. The “Interim Final Rule,” contains risk-management standards for institutions with more than $50 billion in assets. It also places greater responsibility on board members, particularly independent directors, to ensure that the rules are followed and to require that banks have independent audit and risk-management officers who can go straight to the board with concerns. In the Interim Final Rule OCC has explicitly reserved authority to apply the guidelines to an institution with less than $50 billion in assets if the OCC determines that it is highly complex or otherwise presents a heightened risk.

Interim Final Rule

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Subchapter S Bank Association

112 East Pecan St., Suite 2810
San Antonio, TX 78205
Phone: 210-228-9500
Fax: 210-228-0781

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